Yes. This section appears to be consistent with other published guidelines and would promote harmony across Europe.
Yes. However we would value further clarity on what records the EBA expect firms to retain to evidence how the remuneration policies and practices have been implemented in practice (see 2.2).
The assumption is that these guidelines would apply to the population within the scope of this consultation. However, paragraphs 3.1 and 3.2 suggest that this section refers to the institution’s remuneration policies and practices as a whole. Clearly the management body should not be responsible for its own remuneration and therefore we would disagree with 3.1. We feel that further clarification is therefore required in this section.
Clarification is also sought on the meaning of “sound independent advice” and whether being independent is limited to non-executive directors or the Remuneration Committee, or whether internal parties who do not participate in a particular pay arrangement, and are outside of the Retail business line, could be considered independent.
No need for any additional requirements identified.